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Constitutional Law · Rational basis & Footnote Four · Case brief

United States v. Carolene Products Co.

304 U.S. 144 (1938) · Supreme Court of the United States · 1938
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Facts

Carolene Products was indicted for violating the federal Filled Milk Act of 1923, which prohibited shipment in interstate commerce of "filled milk," a product made by combining skimmed milk with non-milk fats or oils. The company sold Milnut, a canned milk product made with skim milk and coconut oil. Carolene Products argued that the Act exceeded Congress's power and violated the Due Process Clause of the Fifth Amendment because the product was wholesome and the prohibition was arbitrary. The case reached the Supreme Court on review of a lower court decision dismissing the indictment.

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Issue

Does the Filled Milk Act of 1923, as applied to interstate shipment of filled milk, violate the Fifth Amendment's Due Process Clause because the prohibition is arbitrary or unsupported by a rational basis?

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Rule

Economic regulation enacted by Congress is presumed constitutional, and courts will uphold it if any state of facts either known or reasonably assumed could support the legislative judgment. Under due process review, courts do not reweigh legislative factfinding where the law has a rational basis.

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Holding

Yes, the Act is constitutional. The Court upheld the Filled Milk Act and reversed the dismissal of the indictment because Congress could rationally conclude that filled milk was injurious to public health or facilitated fraud on consumers.

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Reasoning

Justice Stone explained that regulatory legislation affecting ordinary commercial transactions carries a strong presumption of constitutionality. Even if evidence in the record suggested the product might be wholesome, the Court would not invalidate the statute so long as Congress could reasonably have believed the product posed health risks or invited deception. The Court emphasized that it is enough that facts may be conceived to justify the law, and it deferred to Congress's judgment in the economic sphere. In the famous Footnote Four, the Court suggested that more exacting judicial scrutiny may be appropriate for legislation appearing to conflict with specific constitutional guarantees, restrict political processes, or target discrete and insular minorities.

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Significance

Carolene Products is a foundational case for modern rational-basis review and the New Deal-era shift toward judicial deference in economic regulation. Its Footnote Four became enormously influential in constitutional law by sketching the framework for heightened scrutiny in cases involving fundamental rights, political process restrictions, and prejudice against minorities. It is closely related to Nebbia v. New York, 291 U.S. 502 (1934), Williamson v. Lee Optical of Oklahoma Inc., 348 U.S. 483 (1955), and United States v.ene Products Co., 323 U.S. 18 (1944).

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Citations in this brief — every case checked
Nebbia v. New York, 291 U.S. 502 (1934)
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Williamson v. Lee Optical of Oklahoma Inc., 348 U.S. 483 (1955)
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323 U.S. 18 (1944)
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